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What are Jury Instructions, and How Important Are They To My Personal Injury Case?
What are Jury Instructions, and How Important Are They To My Personal Injury Case?

When you have a personal injury case pending in a court of law, the court will likely issue a scheduling order, which sets the date that the case will be presented to a jury and sets out the deadlines that certain submissions will be due to the court.

These deadlines, once the trial date approaches, will include the date that proposed jury instructions are due.  Jury instructions are the set of legal rules that jurors ought to follow when deciding a case.  Jury instructions are given to the jury by the judge, who usually reads them aloud to the jury.

In most states, these are forms that should be submitted as written with little or no variation.  In order to show the court the source of the content, each instruction will have a notation showing the rule number under the content of the instruction (for example, AMI 206 is Arkansas Model Jury Instruction 206 and might be submitted by the Defendant if they claim that the Plaintiff was partially at fault in a car accident case).

It is important that if you change any of the language in a proposed instruction that you add the word “modified” in parentheses or brackets beside the model jury instruction number.  Then, you should also be prepared to persuade the judge in a pre-trial conference for the need to modify the language of the model instruction rather than merely submitting the instruction as drafted in the model rules.

Many times, there are valid reasons to submit a heavily modified or new instruction, if the case raises a novel issue or one of first impression.  Do jurors read these instructions in the jury room?  It varies from jury to jury, but many juries can decide a case based on the wording in a jury instruction, so the submission of jury instructions are not to be taken lightly.

Discussion of the Jury Charge and Verdict Forms – Personal Injury Lawyer Little Rock, AR

At the conclusion of the set of jury instructions submitted to the court, a verdict form.  The jury verdict can either be a broad sentence with a blank at the end to be filled in by the jury foreman for the amount of the verdict, or the case can be submitted on a series of interrogatories that the jury must decide regarding each issue.  Personal injury attorneys vary in their styles, but most personal injury attorneys will tell you that they would prefer a separate blank on the verdict form for each element of damages sought.

For these reasons, it is always smart to associate a veteran litigator and experienced trial lawyer who has been involved in these particular issues when presenting cases to a jury.

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